DATE LAST MODIFIED: May 25, 2018
Importance of Your Privacy
A Special Note About Children
Children are not eligible to use our Services and we ask that minors (under the age of 13) do not submit any personal information to us or use the Services. Orion does not collect or maintain information from those actually known to be under the age of 13, and no part of Orion’s website, software or services is structured to attract anyone under the age of 13.
Important Categories of Information for you to Know:
- Who we are
- Information we may collect at the Website
- How your information is used
- Where we process data
- Legal basis for data collection
- Altering the information you submit through the Website
- Who We Are
- Orion operates a website located at www.orionmobility.com (the “Website”) and licenses certain relocation and tax software (the “Software”) to its customers.
- Information We Collect
- There are several areas on the Website or in connection with licensing of the Software where you may be asked to enter both personal and non-personal information. We DO NOT sell or share any personal information about you to or with any person or organization except (i) as authorized by you, (ii) as set forth in the relevant portion of the Website or Software, (iii) in connection with providing various Services to you, (iv) as may be required by law or court order, or (v) as otherwise set forth herein. In particular, and not in limitation of the foregoing, information you enter at the Website or within the Software platform will be shared with the vendor(s) or third party services providers with which Orion has entered into a business relationship in order to offer access to the Software and Website.
- Information we receive from you. To use certain of Orion’s Services, you’ll need to provide certain personal information which may include, without limitation, your name, company name, phone number, credit card information and/or e-mail address, as well as other information.
- Technical information we collect. In order for Orion to ensure that we are providing the best possible consumer experience on the Website and within the Software platform, we collect and track certain user information. When you visit the Website, our Web server sends a cookie to your computer. This cookie stores a limited amount of information about your site visit. The cookie tracks aggregate information on how our site is being used, including session counts, navigation patterns, pages visited, etc. These cookies, however, do not store any personally identifiable information such as your name, email address or phone number as you browse the site. When you submit a question, we store your cookie identification in our system. This cookie allows our site to recognize you when you return. Orion may also utilize Web Logs to track aggregate information about how our site is being used. Web Logs track anonymous user information, including the number of visitors to the Website, operating systems, Internet Provider addresses (if publicly available), and browser type. Unlike cookies, Web Logs are maintained only on Orion servers and do not store or place anything on the user’s computer. If you come to the Orion Website from an online banner ad, an anonymous identification number may be passed to the Website. This information cannot be used to gather any personally identifiable information about you. It will only allow us to track the overall effectiveness of our online advertising, marketing and banner advertisement campaigns.
- Information from surveys. You may have the option of completing an online survey at the Website from time to time. Participation in surveys is completely voluntary and it is your choice whether or not you wish to disclose your personal information to us in connection with any such survey.
- Information from the “Contact Us” section of the Website. You may contact Orion through the “Contact Us” feature. Participation in this area is completely voluntary and it is your choice whether or not you wish to disclose your personal information to us.
- Information collected other sections of the Website. Orion may, from time to time, make various resources available to you at the Website or within the Software platform. At times we may collect personal information in connection with providing such services.
- The Website uses Google Analytics, which is a web analytics service provided by Google, Inc. (“Google”), to evaluate your use of the Website. Google Analytics place a third-party cookie on your computer that is then used to compile reports of visitor traffic and internet usage. Google Analytics does not have a database of individual profiles for each visitor and only collects aggregate data
- For information on how Google Analytics uses data please visit “How Google uses data when you use our partners’ sites or apps”, located at www.google.com/policies/privacy/partners/.
- How your information is used
- We use the information you provide to provide the applicable Services to you. Orion does not share your with other third parties for marketing or demographic purposes. In order for us to provide these Services to you, it may be necessary for us to share your personal information with additional third parties for processing. These parties are not allowed to use personally identifiable information except for the purpose of providing these Services. If you do not want your data to be shared, you can choose not to allow the transfer by not using that particular Service. In addition, Orion may disclose account or other personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with Orion’ rights or property, other Website or Software users or anyone else that could be harmed by such activities.
- Orion may be forced to disclose an individual’s personal information when compelled by a lawful request made by a recognized public authority or where required to meet national security and or law enforcement requirements. Orion is subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”).
- In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Orion is potentially liable.
- Where we process data
- If you choose to provide Orion Mobility with information, including personal data from the Website, you understand that we are storing or and/or transferring it to Orion Mobility systems within the United States.
- If you choose to provide Orion Mobility with information, including personal data, from within Orion’s software services, you understand that we are storing and/or processing it only from within Orion’s secure server facilities located in the United States.
- Altering Information You Submit
- Orion understands that the right of access is fundamental to privacy protection. Accordingly, individuals may: (a) obtain from Orion confirmation of whether or not it processes their Personal Data, (b) cooperate with Orion to determine the accuracy and lawfulness of Orion’s processing of Personal Data, and (c) have the data corrected, amended or deleted where it is inaccurate, but only to the extent practicable. Inquires about access should be directed to email@example.com.
- Deleting your information. Federal and state regulations may require that we store questions or submissions for various periods of time. In order to comply with these regulations, we may be unable to delete information from our databases.
- Choice – Timing of Opt-Out. Due to the nature of the services it provides to its clients, it is difficult for Orion to provide individuals the option to opt-out. Orion therefore encourages individuals to first request to opt-out with their employer (i.e., Orion client). In support of the opt-out concept and Orion commitment to the principle of choice, individuals who desire to exclude their Personal Data from the processing Orion performs, they may send a request to firstname.lastname@example.org. Orion will forward such request to its client and together they will determine the best course of action.
- Request to stop receiving emails from us. Periodically, Orion may send you emails to alert you to various opportunities available at the Website or in connection with the Software. If you do not wish to receive any of these offers, please send an e-mail to email@example.com to remove yourself from our mailing list.
For EU Citizens
- Data is collected for Services directly from EU citizens only after explicit opt-in consent is given by the individual.
- Data that is submitted by a third party (typically the employer) on behalf of an individual is collected only out of the necessity for the performance of a contract with the employer to which the data subject is a party.
- EU citizens have the right of access and correction of their personal data.
- EU citizens have the right to request erasure of their data. For data used in the processing of services some data may need to be retained for reasons stated in Article 17; Paragraph 3 of the GDPR.
Orion uses extensive and sophisticated secure technology to protect your data and transmissions between you and Orion. Transmission between browsers and our web server is implemented using Secure Sockets Layer (SSL) technology. This technology requires an SSL-capable browser. Our database is physically separated from our web server and is protected by a physical firewall. Although Orion has taken these reasonable and appropriate measures to ensure that your personal information is delivered and disclosed only in accordance with your instructions, Orion cannot and does not guarantee that the personal information you provide will not be intercepted by others and decrypted.
By e-mail: firstname.lastname@example.org
By Phone: (203) 762-0365
By Mail: Orion Mobility LLC, 4 Mountainview Terrace, suite 101, Danbury, CT 06810
Orion Mobility LLC has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
As a participant in the Privacy Shield, Orion agrees to be subject to the investigatory and enforcement powers of the DOT and FTC. Accordingly, Orion may be required to disclose Personal Data to DOT, FTC, or other applicable U.S. government agencies in response to, e.g., national security needs, law enforcement requirements, or Orion’s liability for onward transfers.
Orion Mobility LLC has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.
Under certain limited conditions it is possible to seek recourse through last resort binding arbitration.
We may, in the future, sell or otherwise transfer some or all of our assets or equity to a third party. Your personally identifiable information and other information we obtain from you via the Website or Software may be disclosed to any potential or actual third party purchasers of such assets or equity and may be among the assets transferred.
PLEASE PRINT AND RETAIN A COPY OF THIS AGREEMENT FOR YOUR RECORDS.